Privacy Policy

This privacy policy (“Policy”) sets out how Vi Na Data Information Technology - Service Joint Stock Company (“GreenNode”) collects, uses, stores, shares and protects personal data when individuals interact with GreenNode, including through GreenNode’s website, portal, console, accounts, services, sales, marketing and Customer support activities, events and other official communication channels. 

This Policy applies to personal data that GreenNode processes in the circumstances described in Article 2 - Scope of application and roles of GreenNode. For data, content, files, applications, workloads or other data that a Customer inputs, stores, transmits, processes or generates when using GreenNode services (“Customer Data”), the processing of such data is described in Article 4 - Customer Data and may be governed by the Terms of Service, contract, personal data processing agreement or equivalent documents applicable between GreenNode and the Customer. 

This Policy is developed in accordance with Vietnamese laws on personal data protection. GreenNode may update this Policy from time to time to reflect changes in laws, products, services or GreenNode’s personal data processing activities.

Definitions

• In this Privacy Policy, the following terms shall be construed as follows:
  • “Personal Data” means digital data or information in other forms that identifies or helps identify a specific person, including basic personal data and sensitive personal data. Personal data that has been de-identified is no longer considered personal data.
  • “Basic Personal Data” and “Sensitive Personal Data” have the meanings prescribed by the Applicable Laws.
  • “Personal Data Subject” means the person reflected by the personal data.
  • “Personal Data Processing” means any activity affecting personal data, including one or more activities such as: collecting, analyzing, aggregating, encrypting, decrypting, editing, deleting, destroying, de-identifying, providing, disclosing, transferring personal data and other activities affecting personal data.
  • “Personal Data Controller”, “Personal Data Processor” and “Personal Data Controller and Processor” have the meanings prescribed by the Applicable Laws.
  • “GreenNode Services” means the products, services, solutions, platforms, tools, features, technical infrastructure, computing resources, technical support services and other related services provided or operated by GreenNode from time to time.
  • “GreenNode Platform” means the website, portal, console, dashboard, online accounts, administration interfaces, service management systems or other digital platforms provided or operated by GreenNode for Customers, Users or other individuals to access, register for, manage, configure, use or interact with the GreenNode Services.
  • “Terms of Service” means the terms of service published by GreenNode on its website or the GreenNode Platform, as updated from time to time, applicable to Customers’ or Users’ access to, registration for, purchase, use or receipt of the GreenNode Services, including the policies, guidelines, service description documents, technical documents, supplemental terms or other ancillary documents referenced, attached or applied by GreenNode for each GreenNode Service.
  • “GreenNode Interaction Channels” means the official communication channels between individuals, Customers, Users, partners or organizations and GreenNode, including email, telephone, support requests recorded on the system, online forms, meetings, events, webinars, Customer care channels, sales channels, marketing channels or other communication channels used by GreenNode from time to time.
  • “Customer” means an organization or individual that uses, registers to use, purchases, trials, evaluates or interacts with the GreenNode Interaction Channels in relation to the GreenNode Services, including prospective Customers, Customers requesting consultation, Customers purchasing services directly from the portal and Customers entering into separate contracts with GreenNode.
  • “User” means an individual who accesses, uses or is permitted by a Customer to access, administer, operate or interact with the GreenNode Services or the GreenNode Platform.
  • “Customer Data” means the data defined in Article 4.
  • “Third Party” means an organization or individual other than GreenNode, the Customer, the User or the relevant Personal Data Subject.
  • “Applicable Laws” means the Law on Personal Data Protection 2025 and other implementing legal instruments, or any legal instruments replacing, amending or supplementing such instruments, applicable to the personal data processing activities under this Policy.

Scope of application and roles of GreenNode

• This Policy applies to GreenNode’s processing of Personal Data when an individual accesses or uses the GreenNode Platform, uses or interacts with the GreenNode Services, contacts GreenNode through the GreenNode Interaction Channels, or has a relationship with GreenNode in the capacity of a Customer, User, representative, personnel, contact person or authorized person of a Customer, partner, supplier or other organization.
• For Personal Data that GreenNode processes for GreenNode’s own purposes, GreenNode processes such data in the capacity of a Personal Data Controller or a Personal Data Controller and Processor.
• For Customer Data, GreenNode may process such data in the capacity of a Personal Data Processor or another role as agreed between GreenNode and the Customer, depending on the nature of the GreenNode Services, the content of the applicable agreement and the Applicable Laws. The processing of Customer Data is further described in Article 4 and may be governed by the Terms of Service, contract, personal data processing agreement or equivalent document applicable between GreenNode and the Customer.
• This Policy does not apply to websites, services, products, applications or personal data processing activities of Third Parties that GreenNode does not own, control or operate, even where such websites, services, products or applications are linked, integrated or displayed through the GreenNode Platform or the GreenNode Services. The processing of personal data by Third Parties is governed by the privacy policy or separate terms of such Third Parties.

Personal Data collected by GreenNode

• Basic Personal Data

  Depending on each circumstance and on the provision, operation or use of the relevant GreenNode Services, GreenNode Platform or GreenNode Interaction Channels, GreenNode may collect and process some or all of the following Basic Personal Data under the Applicable Laws, including:

  • surname, middle name and birth name, other names if any;
  • date of birth; date of death or disappearance if any;
  • gender;
  • contact address, nationality;
  • image of the individual;
  • phone number, identity card number, personal identification number, passport number and other personal identification codes issued by competent state authorities;
  • information about the individual’s digital accounts, personal data reflecting the individual’s activities or interactions on the GreenNode Platform or the GreenNode Services, to the extent classified as Basic Personal Data under the Applicable Laws; and
  • other Basic Personal Data under the Applicable Laws.

• Sensitive Personal Data

  Depending on each circumstance and on the provision, operation or use of the relevant GreenNode Services, GreenNode Platform or GreenNode Interaction Channels, GreenNode may collect and process some or all of the following Sensitive Personal Data under the Applicable Laws, including:

  • Login names and access passwords of bank accounts; bank card information, data on transaction history of bank accounts; financial and credit information and information on customers’ activities and transaction histories in finance, securities and insurance at credit institutions, foreign bank branches, payment intermediary service providers, securities and insurance organizations and other licensed organizations;
  • Data on behavior tracking and activities of using telecommunications services, social networks, online media services and other services in cyberspace; or
  • other Sensitive Personal Data under the Applicable Laws.

• Data arising from the use of services

  Depending on each circumstance and on the provision, operation or use of the relevant GreenNode Services, GreenNode Platform or GreenNode Interaction Channels, GreenNode may collect and process some or all of the information arising from the Customer’s access to, use, configuration, administration, operation of or interaction with the GreenNode Services or the GreenNode Platform, to the extent that such information is or contains Personal Data under the Applicable Laws, including:

  • account information, user identifiers, roles, access rights, account settings, account status and organizations associated with the account;
  • login information, authentication information, login history, access history, authentication logs, audit logs, security logs and similar information relating to account access, authentication, administration or security;
  • device information, IP address, browser, operating system, device identifiers, session identifiers, access time, access source and similar technical information;
  • data on activities, operations, configurations, events, usage metrics, service metadata, telemetry, diagnostic data, technical logs and similar information arising in the course of using the GreenNode Services or the GreenNode Platform;
  • information relating to support requests, tickets, communication content, attachments, diagnostic information, survey responses, call or meeting recordings if any, and other information provided by the individual or arising in the course of contacting GreenNode;
  • information relating to orders, service packages, service fees, invoices, vouchers, payment status, tax information, accounting information, contact persons in charge of purchasing, payment or contracts; and
  • other information arising from access to, use, configuration, administration, operation of or interaction with the GreenNode Services, the GreenNode Platform or the GreenNode Interaction Channels, to the extent that it is or contains Personal Data under the Applicable Laws.

• Collection of personal data

  Depending on each circumstance and on the provision, operation or use of the relevant GreenNode Services, GreenNode Platform or GreenNode Interaction Channels, GreenNode may collect the data referred to in Clauses 3.1, 3.2 and 3.3 from one or more of the following sources:

  • directly from the individual when the individual provides information to GreenNode, creates an account, uses the GreenNode Platform, uses the GreenNode Services, contacts GreenNode or interacts with GreenNode through the GreenNode Interaction Channels;
  • from the Customer, User or organization that the individual represents, works for, is authorized by or is otherwise related to;
  • from the individual’s access to, use, configuration, administration of or interaction with the GreenNode Platform or the GreenNode Services;
  • from cookies, pixels, SDKs, web beacons, logs, telemetry or similar technologies when the individual accesses or uses the GreenNode Platform, as further described in Article 13; or
  • from Third Parties to the extent consistent with the Applicable Laws, including partners, service providers, payment processors, verification providers, integration platforms, public sources or other lawful sources.
     

Customer Data

• Customer Data means data, content, files, applications, workloads, databases, model input data, model output data, prompts, datasets, images, videos, recordings, documents or other data that the Customer or the Customer’s Users upload, store, transmit, process, generate or operate when using the GreenNode Services.
• Customer Data does not fall within the scope of this Policy, unless expressly provided otherwise. For Customer Data, GreenNode does not determine the purposes and means of data processing in the capacity of a Personal Data Controller, unless otherwise agreed in writing between the parties. The Customer is responsible for determining the data to be placed into the GreenNode Services, the purposes of processing, the legal bases for processing, the notification to Personal Data Subjects, the collection of consent where necessary, the implementation of Personal Data Subjects’ rights and other compliance obligations under the Applicable Laws.
• For Customers using the GreenNode Services on a self-service basis, the processing of Customer Data may be governed by the Terms of Service, data processing terms, service policies or equivalent documents applicable to the relevant GreenNode Services.
• For Customers entering into separate contracts with GreenNode, the processing of Customer Data may be governed by the contract, order, personal data processing agreement (“DPA”) or equivalent document between GreenNode and the Customer.
• In the event of any conflict between this Policy and the Terms of Service, contract, personal data processing agreement or equivalent document between GreenNode and the Customer in relation to Customer Data, the document specifically applicable to Customer Data shall prevail to the extent of such conflict.

Purposes of Personal Data processing

• Necessary purposes of Personal Data processing

  GreenNode may process Personal Data for one or more of the following necessary purposes:

  • identifying, authenticating and managing individuals when they access, register, log in, use or interact with the GreenNode Platform, the GreenNode Services or the GreenNode Interaction Channels;
  • creating, maintaining, administering, protecting and supporting accounts, access rights, user roles, account settings and related functions;
  • receiving, responding to, managing and handling consultation requests, support requests, tickets, complaints, feedback, notices or other communications from individuals, Customers, Users or relevant organizations;
  • sending service notices, technical notices, security notices, operational notices, transactional notices, legal notices or other information necessary for the use of the GreenNode Services, the GreenNode Platform or the relationship between GreenNode and the Customer;
  • verifying information, handling access requests, support requests or requests to exercise the rights of Personal Data Subjects under this Policy and the Applicable Laws;
  • providing, operating, maintaining, managing, configuring, supporting and improving the stability, reliability, performance and availability of the GreenNode Services or the GreenNode Platform;
  • processing service registrations, orders, contracts, annexes, purchase orders, service packages, service activation, service changes, renewal, suspension, termination or other transactions relating to the GreenNode Services;
  • managing Customer relationships, partner relationships, information of representatives, contact persons, technical contacts, persons in charge of purchasing, payment or contracts, or operational focal points of Customers, partners, suppliers or relevant organizations;
  • processing service fees, payments, invoices, vouchers, reconciliation, refunds if any, tax, accounting and audit obligations and related financial activities;
  • monitoring, detecting, preventing, investigating or handling technical errors, operational incidents, fraud, abuse, unauthorized access, violations of terms of service, security risks or other threats affecting the systems, accounts, GreenNode Services, GreenNode Platform, Customers, Users or Third Parties;
  • protecting the rights, legitimate interests, assets, systems, infrastructure, information security, cybersecurity, reputation and lawful business operations of GreenNode, Customers, Users or Third Parties;
  • keeping records, maintaining transaction evidence, handling disputes, complaints and claims, and enforcing contracts, terms of service, service policies or GreenNode’s legal rights;
  • complying with the Applicable Laws, requests of competent state authorities, reporting obligations, audit obligations, retention obligations, obligations regarding personal data protection, information security, cybersecurity, tax, accounting or other legal obligations.

• Optional processing purposes

  To the extent permitted by the Applicable Laws or where appropriate grounds exist, Users may consent or decline to consent to GreenNode processing Personal Data for one or more of the following purposes:

  • sending newsletters, introductory materials, marketing information, information on events, seminars, webinars, promotional programs, offers, surveys or other information about GreenNode’s products, services, solutions or activities;
  • personalizing content, recommendations, displayed information, user experience, support information or the individual’s interactions on the GreenNode Platform, the GreenNode Services or the GreenNode Interaction Channels;
  • analyzing usage trends, measuring campaign effectiveness, assessing interest in products or services, conducting market research, improving Customer experience, improving website content or optimizing how GreenNode interacts with individuals and Customers;
  • using cookies, analytics technologies, measurement technologies, marketing technologies or similar technologies, as further described in Article 13;
  • carrying out other activities that the individual has consented to, requested or opted in to from time to time.
• Declining, withdrawing consent or changing choices regarding processing purposes
  Individuals may decline, withdraw their consent or change their choices with respect to the purposes of Personal Data processing. Declining, withdrawing consent or changing choices may result in the individual no longer receiving certain corresponding information, content, features, personalized experiences or optional activities, but does not affect GreenNode’s processing of Personal Data for the necessary purposes or for other purposes for which the Applicable Laws permit processing without consent.

Rights of Personal Data Subjects

• Personal Data Subjects have the following rights with respect to their Personal Data in accordance with the Applicable Laws, including:
  • to be informed of Personal Data processing activities;
  • to consent or decline to consent, and to request the withdrawal of consent to Personal Data processing;
  • to view, correct or request the correction of Personal Data;
  • to request the provision, deletion or restriction of processing of Personal Data; to submit requests objecting to Personal Data processing;
  • to lodge complaints or denunciations, initiate lawsuits and claim compensation for damages in accordance with law;
  • to request competent authorities or agencies, organizations and individuals involved in Personal Data processing to implement measures and solutions to protect their Personal Data in accordance with law; and
  • other rights under the Applicable Laws.
• The exercise of the rights referred to in Clause 6.1 must comply with the Applicable Laws, this Policy, the Terms of Service, contract, personal data processing agreement or equivalent document applicable to the relationship between GreenNode and the Customer or the Personal Data Subject, as the case may be.
• Where a request of a Personal Data Subject relates to accounts, environments, systems, Customer Data or resources managed by the Customer, GreenNode may need to coordinate with the Customer, the account administrator or the relevant organization to handle such request in accordance with the Applicable Laws and the applicable agreement.
• The rights of Personal Data Subjects may be restricted, delayed or refused in the circumstances permitted by the Applicable Laws, including where the exercise of such rights may affect the rights and legitimate interests of GreenNode, Customers, Users, other Personal Data Subjects or Third Parties; affect the safety, security or integrity of systems; or hinder legal compliance, contract performance, dispute resolution, investigations, audits or the protection of the legal rights of GreenNode or Third Parties.

How Personal Data Subjects exercise their rights

• Personal Data Subjects may exercise their rights through one or more methods provided by GreenNode from time to time, including:
  • for Users with accounts on the GreenNode Platform, through the account information management or update functions on the GreenNode Platform, if such functions are available; or
  • through the contact points specified in Article 18 or other methods notified by GreenNode from time to time.
• For requests that can be made directly on the GreenNode Platform, including requests to withdraw consent, delete accounts, restrict Personal Data processing or object to Personal Data processing, Personal Data Subjects may need to follow the process displayed on the GreenNode Platform, including selecting the corresponding function, confirming the request and entering a security code or performing other authentication measures as required by the system.
• After a request has been recorded on the GreenNode Platform, GreenNode may allow the Personal Data Subject to cancel or withdraw the request within a certain period before the request is fully processed. The period for cancelling or withdrawing a request, if any, will be displayed on the GreenNode Platform or notified to the Personal Data Subject by appropriate means.
  If the Personal Data Subject does not cancel or withdraw the request within the period notified by GreenNode, GreenNode will proceed to process the request in accordance with the applicable process, this Policy and the Applicable Laws. Depending on the type of request, the processing of the request may result in the termination, restriction or change of the ability to access or use the relevant account, GreenNode Platform or GreenNode Services, and GreenNode may still continue to store or process certain Personal Data if such storage or processing is necessary, required or permitted by the Applicable Laws.
• Upon receiving a request, GreenNode may require the Personal Data Subject to provide the information necessary to verify identity, verify representative authority if any, determine the scope of the request and process the request in accordance with the Applicable Laws. The Personal Data Subject is responsible for ensuring that the information provided to GreenNode when making a request is complete, accurate, up to date and lawful.
• GreenNode will process requests of Personal Data Subjects within the time limits prescribed by the Applicable Laws. Where the Applicable Laws do not prescribe a specific time limit, GreenNode will process the request within a reasonable period, taking into account the nature, scope and complexity of the request, the number of requests being processed and other relevant factors.
• GreenNode may refuse or restrict the processing of a request in the circumstances permitted by the Applicable Laws, including where the request lacks sufficient grounds, identity or representative authority cannot be verified, the request affects the rights or legitimate interests of other individuals or organizations, the request relates to Customer Data controlled by the Customer, or GreenNode needs to continue processing Personal Data to comply with law, perform contracts, protect legal rights, ensure system safety or resolve disputes.
• For accounts belonging to organizations, GreenNode may notify, forward or coordinate with the Customer or the account administrator of such organization to handle the request, where such coordination is necessary or consistent with the Applicable Laws and the agreement between GreenNode and the Customer.

Security of Personal Data

• GreenNode applies appropriate managerial, technical and organizational measures to protect Personal Data in accordance with the Applicable Laws, taking into account the nature of the Personal Data, the purposes of processing, processing risks, technical capabilities, implementation costs and the operational requirements of the relevant GreenNode Services, GreenNode Platform or GreenNode Interaction Channels.
• GreenNode’s measures to protect Personal Data may include, depending on each case, access controls, authorization, authentication, logging and monitoring of access activities, encryption where appropriate, backups, environment segregation, change controls, vulnerability management, security testing, incident management, personnel training, vendor management and other protective measures in accordance with GreenNode’s internal policies.
• GreenNode limits access to Personal Data to the extent necessary for lawful processing purposes, the provision and operation of the GreenNode Services, the support of Customers or Users, compliance with the Applicable Laws, the protection of systems or the exercise of GreenNode’s legal rights and obligations.
• GreenNode may use service providers, contractors, consultants or other Third Parties to support the provision, operation, security or management of the GreenNode Services, the GreenNode Platform or the GreenNode Interaction Channels. In such cases, GreenNode will apply appropriate measures to manage the processing of Personal Data by such parties in accordance with the Applicable Laws and the relevant agreements.
• Specific security measures applicable to each GreenNode Service, the GreenNode Platform or Customer Data may be further provided in the Terms of Service, contract, personal data processing agreement, service security policy or equivalent applicable document.

Sharing of Personal Data

• GreenNode may share Personal Data to the extent necessary to carry out the processing purposes set out in this Policy, in accordance with the Applicable Laws and the applicable agreement between GreenNode and the Customer or the Personal Data Subject, and the corresponding legal bases for personal data processing.
• GreenNode may provide, share or transfer Personal Data:
  • to affiliates, companies within the same corporate group, service providers, contractors, consultants, payment processors, verification providers, technical support providers, hosting providers, analytics providers, security providers, Customer relationship management providers or other Third Parties supporting GreenNode, where such provision, sharing or transfer is necessary for the provision, operation, management, security, support, payment, Customer care, internal administration or performance of other activities relating to the GreenNode Services, the GreenNode Platform or the GreenNode Interaction Channels;
  • to Customers, account administrators, representatives, authorized persons, contact persons or relevant personnel of the relevant organization, where such provision, sharing or transfer is necessary for the management of accounts, contracts, transactions, invoices, support requests, incidents, notices, access rights, the use of the GreenNode Services or the relationship between GreenNode and the Customer, partner, supplier or relevant organization, to the extent consistent with the role, access rights or relationship of the data recipient;
  • where necessary to comply with the Applicable Laws or valid requests of competent state authorities, to perform reporting, audit or retention obligations, to protect legal rights and interests, to protect systems or information security, to resolve disputes, or to investigate, prevent or handle violations. Data recipients in such cases may include competent state authorities, courts, arbitrators, law enforcement agencies, regulatory authorities, auditors, legal advisors, financial advisors or relevant Third Parties; and
  • in the context of a reorganization, division, separation, merger, consolidation, assignment, sale of assets, transfer of business operations, cessation of operations, dissolution, bankruptcy or similar transaction involving all or part of GreenNode’s business operations, assets, rights or obligations, to the extent consistent with the Applicable Laws and the established purposes of Personal Data processing.
• For cases of sharing Personal Data that do not fall within the necessary or permitted cases under Clause 9.2, GreenNode will only carry out such sharing with the consent of the relevant Personal Data Subject or where another lawful basis exists under the Applicable Laws.

Cross-border transfer of Personal Data and processing locations

• Personal Data may be processed, stored, accessed, provided or transferred in Vietnam or in other countries or territories, depending on the GreenNode Services, the GreenNode Platform, the GreenNode Interaction Channels, systems, service providers, infrastructure locations, service regions, the Customer’s choices, the applicable agreement and the Applicable Laws.
• For Customer Data, the location of processing, storage, access, provision or transfer may depend on the service region, infrastructure location, the Customer’s configuration choices, purchase orders, contracts, the Terms of Service, the personal data processing agreement or equivalent documents applicable to the relevant GreenNode Services.
• Where GreenNode is the party carrying out cross-border transfers of Personal Data within GreenNode’s scope of responsibility, GreenNode will perform the corresponding obligations under the Applicable Laws, including preparing, retaining, submitting, updating or supplementing the impact assessment dossier for cross-border transfer of Personal Data, applying appropriate protective measures and complying with other requirements of competent state authorities, if and to the extent required by the Applicable Laws.

Retention period

• GreenNode retains Personal Data for the period necessary to fulfill the processing purposes described in this Policy, unless a longer retention period is required or permitted by the Applicable Laws.
• The retention period of Personal Data may depend on the type of Personal Data, the purposes of processing, the account maintenance period, the period of use of the GreenNode Services, the contract term, legal obligations, tax, accounting, audit and cybersecurity obligations, security requirements, record-keeping requirements, dispute resolution requirements, limitation periods for complaints, limitation periods for lawsuits or the legitimate interests of GreenNode, Customers, Users or Third Parties.
• Account data, transaction data, payment data, invoices, vouchers, support data, access logs, security logs, service usage data, marketing data, cookies data and other types of Personal Data may have different retention periods depending on each system, the purposes of processing and the Applicable Laws.
• When Personal Data is no longer necessary for the processing purposes, GreenNode will delete, destroy, de-identify, anonymize, restrict access to or apply other appropriate handling measures to such data upon expiry of the periods specified in the Terms of Service and this Policy and in accordance with the Applicable Laws.
• The retention period of Customer Data, including the deletion, export, backup, restoration or termination of processing of Customer Data, may be governed by the Terms of Service, contract, personal data processing agreement, service policies or equivalent documents applicable to the relevant GreenNode Services.

Notification and handling of Personal Data violations

• GreenNode maintains processes for receiving, assessing, preventing, remediating and handling incidents or violations of personal data protection regulations within GreenNode’s scope of responsibility under the Applicable Laws.
• Where a violation of personal data protection regulations is detected that may cause harm to national defense, national security, social order and safety, or infringe upon the life, health, honor, dignity or property of Personal Data Subjects, GreenNode will perform its obligation to notify the specialized personal data protection authority within the time limit prescribed by the Applicable Laws, if and to the extent that GreenNode is obligated to make such notification.
• GreenNode will coordinate with competent state authorities, Customers, service providers or relevant Third Parties in handling violations of personal data protection regulations, to the extent required by the Applicable Laws or the applicable agreement.
• Notification to Personal Data Subjects, Customers or Third Parties of incidents or violations of personal data protection regulations will be made where required by the Applicable Laws, where required by the applicable agreement, or where GreenNode determines that such notification is appropriate in each specific case.
• GreenNode is not responsible for incidents arising from environments, accounts, settings, systems, applications, content, Customer Data or conduct managed or controlled by Customers, Users or Third Parties, unless otherwise provided by the Applicable Laws or the agreement between GreenNode and the Customer.

Cookies

• GreenNode may use cookies, pixels, software development kits, web beacons, logs, analytics technologies, measurement technologies, marketing technologies or similar technologies on the GreenNode Platform to operate the platform, remember users’ choices, secure sessions, analyze performance, measure interactions, improve experience or fulfill other purposes (“Cookies”). To the extent that these technologies collect, generate or are associated with Personal Data, the use of these technologies will be carried out in accordance with this Policy and the Applicable Laws.
• With respect to Cookies, GreenNode will only use them with the consent of the relevant Personal Data Subject or where another lawful basis exists under the Applicable Laws. Personal Data Subjects may decline, withdraw their consent or change their choices with respect to such cookies and similar technologies through the cookies preference tools, account settings, browser settings, device settings or other methods supported by GreenNode from time to time.
  However, disabling or declining certain Cookies and similar technologies may affect the ability to access and use, and the performance, functionality or experience on, the GreenNode Platform.
• Cookies may be classified into one or more of the following categories:
  • cookies necessary for the GreenNode Platform to operate, maintain sessions, authenticate users, secure accounts or provide functions requested by the individual;
  • functional cookies to remember the individual’s preferences, settings, language, region or other choices;
  • analytics or measurement cookies to help GreenNode understand how individuals access, use or interact with the GreenNode Platform, content or the GreenNode Services; and
  • marketing cookies or similar technologies to measure campaign effectiveness, provide more relevant content or support marketing activities, if and to the extent permitted by the Applicable Laws.
• GreenNode may allow Third Parties to place or use cookies and similar technologies on the GreenNode Platform to provide analytics, measurement, security, marketing or other functions for GreenNode. To the extent that a Third Party processes Personal Data on behalf of GreenNode or under GreenNode’s instructions, GreenNode will apply appropriate measures in accordance with the Applicable Laws and the relevant agreement with such Third Party. To the extent that a Third Party processes Personal Data for its own purposes or under its own policies, such processing may be governed by the privacy policy, cookies policy or separate terms of that Third Party. GreenNode recommends that Users read such policies and terms to better understand how Third Parties use Cookies and process Personal Data.

Marketing information

• GreenNode may send marketing information, newsletters, introductory materials, information on events, seminars, webinars, promotional programs, offers, surveys or other information about GreenNode’s products, services, solutions or activities to the extent that the User consents and the Applicable Laws permit.
• GreenNode will provide appropriate methods for individuals to decline or unsubscribe from certain marketing information, for example through unsubscribe links, account settings, choices in forms, or by contacting GreenNode in accordance with Article 18.
• An individual’s refusal or unsubscription from receiving marketing information does not affect GreenNode’s sending of service notices, technical notices, security notices, transactional notices, legal notices or other information necessary for the use of the GreenNode Services, the GreenNode Platform or the relationship between GreenNode and the Customer.

Children’s data

• The GreenNode Services and the GreenNode Platform are designed primarily for businesses, organizations, experts, professional users or individuals with sufficient capacity to set up, manage or use technology services. GreenNode does not provide the GreenNode Services directly to children or knowingly collect children’s Personal Data through the GreenNode Platform, unless permitted by the Applicable Laws and appropriate grounds exist.
• The Customer is responsible for ensuring that the data provided for GreenNode’s collection under Article 3 of this Policy does not include children’s Personal Data, unless the Customer has grounds to determine that such provision is consistent with the Applicable Laws, including having a lawful basis for processing, making the required notifications, obtaining the necessary consent or confirmation and ensuring the rights of children or their legal representatives.

Third-Party links and services

• The GreenNode Platform or the GreenNode Services may contain links, integrations, utilities, content, applications, services or features of Third Parties that GreenNode does not own, control or operate.
• This Policy does not apply to websites, applications, services, content, systems or Personal Data processing activities of Third Parties. The processing of Personal Data by Third Parties is governed by the personal data protection policy, privacy policy, terms of use or equivalent documents of such Third Parties.
• Individuals should review the personal data protection policy, privacy policy and applicable terms of Third Parties before providing Personal Data, using services, connecting accounts or interacting with Third Parties through the GreenNode Platform or the GreenNode Services.
• GreenNode is not responsible for the Personal Data processing activities, content, features, security, accuracy or operations of Third Parties’ websites, applications, services or systems, unless otherwise provided by the Applicable Laws.

Updates to this Policy

• GreenNode may update, amend or replace this Policy from time to time to reflect changes in the Applicable Laws, products, services, technologies, Personal Data processing activities, operating models or business requirements of GreenNode.
• The updated version of this Policy will be published on the GreenNode Platform and notified to Users by appropriate means. The effective date or the latest update date of the Policy will be indicated in the Policy, in GreenNode’s notice or at the location where the Policy is published.
• An individual’s continued access to the GreenNode Platform, use of the GreenNode Services or interaction with GreenNode after the updated version of the Policy takes effect shall be construed as the individual having been informed of such updated version, unless the Applicable Laws require another form.

Contact

• If there are any questions, requests, complaints or suggestions relating to this Policy or GreenNode’s processing of Personal Data, individuals may contact GreenNode using the following information:
  -    VI NA DATA INFORMATION TECHNOLOGY - SERVICES JOINT STOCK COMPANY
  -    Address: Golden King Building, 15 Nguyen Luong Bang, Tan My Ward, Ho Chi Minh City, Vietnam
  -    Email for personal data protection matters: dpo@greennode.ai 
  -    Support hotline: 1900 1549
• GreenNode may require individuals to provide the information necessary to verify identity, verify representative authority, determine the scope of the request and process the request in order to ensure compliance with this Policy and the Applicable Laws.
• For requests relating to accounts, environments, systems or Customer Data managed by the Customer, GreenNode may instruct the individual to contact the Customer, the account administrator or the relevant organization, or coordinate with such parties to the extent consistent with the Applicable Laws and the applicable agreement.